Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding involves a deficiency in the amount of $16,545.63 in income and victory tax for the calendar year 1943 and negligence penalties in the amounts of $712 and $827.28 for the calendar years 1942 and 1943, respectively. The year 1942 is involved because of the forgiveness feature of section 6 of the Current Tax Payment Act of 1943. The asserted penalty for 1942 is based on the deficiency...
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